Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3760

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2024 THROUGH SEPTEMBER 30, 2024

In accordance with the Order Establishing Procedures for Interim Compensation and

Reimbursement of Expenses for Retained Professionals, dated August 18, 2023 [Docket No.

2094] (the "Interim Compensation Order"),2 Kroll, LLC ("Kroll") hereby submits this monthly

statement (the "Monthly Fee Statement") seeking compensation for services rendered and

reimbursement of expenses incurred as forensic investigators to Luc A. Despins, in his capacity

as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok, for

the period from September 1, 2024 through and including September 30, 2024 (the "Fee

Period"). By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees

and 100% of all expenses actually and necessarily incurred for services rendered during the Fee

Period, in the amounts of \$47,034.52 and \$10,204.83, respectively.

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, service line, standard rate, discounted rate, total hours, and total fees earned for each Kroll individual who provided services during the Fee Period. The rates charged by Kroll for services rendered to the Trustee are discounted per the engagement letter to the rates that Kroll charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Project Category.

3. Attached hereto as Exhibit C is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Matter ID.

4. Attached hereto as Exhibit D is a summary of Kroll's expenses incurred and reimbursement sought for the Fee Period organized by Expense Type.

5. Attached hereto as Exhibit E are Kroll's fee statements for services provided during the Fee Period.

6. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn

(holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

7. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kroll (Attn: Allen Pfeiffer (allen.pfeiffer@kroll.com) and (ii) the Notice Parties by email no later than November 20, 2024 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

8. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, the estate shall promptly pay Kroll 80% of the fees and 100% of the expenses identified in this Monthly Fee Statement.

9. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estate shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not

resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing.

Allen Pfeiffer KROLL, LLC 55 East 52nd Street, Floor 17 New York, New York 10055 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on October 30, 2024, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

Dated: October 30, 2024 By: /s/ G. Alexander Bongartz

New York, New York G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

Timekeeper Title Service Line Standard Discounted Total Total Fees

Parizek, Pam Managing Director Forensic Investigations S 890 S 712 6.5 S 4.628.00

Barker, James Associate Managing Forensic Investigations S 710 S 639 9.8 S 6,262.20

Lazarus, Jordan Senior Manager Forensic Investigations S 575 S ਦੇ 18 14.8 S 7.659.00

Lomas. Adam Senior Manager Forensic Investigations S 575 S 218 53.7 ి 27.789.75

Ling, Bryant Associate Managing Cyber Risk S રેરે રેણે S 495 3.6 S 1.782.00

Levenson, Patrick Associate Manager Forensic Investigations S 420 S 378 16.1 S 6.085.80

Spier, Tre Research Analyst Forensic Investigations S 245 S 221 11.2 S 2.469.60

Welby, Jackie Research Analyst Forensic Investigations S 245 S 221 વે રે S 2.116.80

Total Hours and Fees: 125.3 ದ 58,793.15

Time Period: September 1-30, 2024.

U.S. Trustee Task Code and Project Category Hours Billed Fees Billed

B160 Fee/Employment Applications 5.0 S 3.073.75

B181 Preference Analysis and Recovery Actions S B182 Post-Petition Transfers and Recovery Actions S B190 Other Contested Matters (excl. assumption/reject S

B261 Investigations 120.3 S 55,719.40

00001 General Debtor Representation 5.0 S 3.073.75 00002 Asset Recovery Investigation and Litigation 120 3 S 55,719.40

00004 Bravo Luck Adversary Proceeding S

00006 SN Apartment Adversary Proceeding S 00007 Greenwich Land Adversary Proceeding S

00010 Interpleader Adversary Proceeding S

00012 Golden Spring Adversary Proceeding S

00015 Lamp Capital Adversary Proceeding S

00017 Rule of Law Adversary Proceeding S

00019 Leading Shine Adversary Proceeding S

Expense Category Matter ID Task Code Expense Amount

Database and Research Fees for September Golden Spring Adversary Proceeding Asset Analysis and Recovery 766.18 Database and Research Fees for September Asset Recovery Investigation and Litigation Asset Analysis and Recovery 4.628.45 Valid8 Charges General Debtor Representation Case Administration 4.810.20

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Respond to inquiry from NPM Law [J. Graham] re: mechanics of transfers to 0.3 \$ 518 \$

and Litigation Investigations Respond to inquiry from NPM Law [P. Linsey] re: transfers with respect to 0.4 \$ 518 \$

Lazarus, Jordan 9/5/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, P. Parizek, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], and P.

business intelligence updates and related

and Litigation Investigations Reconciliation of Debtor-related accounts

issued; compose related email to K.

at 20 financial institutions for follow-up

and Litigation Investigations Meeting with client or counsel 0.8 \$ 639 \$

and Litigation Investigations Respond to inquiry from Paul Hastings

and Litigation Investigations Correspondence/email with P.Parizek re

and Litigation Investigations Meeting re: transaction activity with

investigative updates, with Paul Hastings

L. Song]; NPM Law [P. Linsey]; and P. Parizek, J. Lazarus, and J. Barker. 0.8 \$ 518 \$

and Litigation Investigations Email team re: agenda items, email

weekly call with A. Lomas, J. Lazarus, J. Barker and Paul Hastings [L. Despins, N.

Law [P. Linsey] re:

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Email corresponce with technology team re;

[.2], email counsel re: same 0.3 \$ 712 \$

[.1].

and Litigation Investigations Respond to inquiry from Paul Hastings [E. Sutton] re: transfers to 0.5 \$ 518 \$

and Litigation Investigations Research with respect to transfers

and Litigation Investigations Respond to inquiry from NPM Law [K.

and Litigation Investigations Respond to inquiry from Paul Hastings

and Litigation Investigations Preliminary review of additional criminal trial exhibits uploaded to Relativity; compose instructions to M. Bottos re: review of criminal trial exhibits. 0.3 \$ 518 \$

and Litigation Investigations Review communications regarding

and Litigation Investigations Correspondence/email regarding 0.4 \$ 495 \$

and Litigation Investigations Correspondence/email - with P.Levinson

Levenson, Patrick 9/10/2024 Asset Recovery

and Litigation Investigations Conducted

and Litigation Investigations Correspond with data team re:

[.2], review updates re:

and Litigation Investigations Computer forensic examination 0.9 \$ 495 \$

and Litigation Investigations Correspondence/email regarding 0.1 \$ 495 \$

Lazarus, Jordan 9/11/2024 Asset Recovery

and Litigation Investigations Meetings and correspondence with A.

Lazarus, Jordan 9/11/2024 Asset Recovery

and Litigation Investigations Review Relativity for supporting documentation for payments made to 1.0 \$ 518 \$

and Litigation Investigations Review A. Lomas summary of updated Rule 2004 subpoenas [.1]. 0.1 \$ 712 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Levenson, Patrick 9/11/2024 Asset Recovery Investigations Conducted

Investigation records requests.

Ling, Bryant 9/11/2024 Asset Recovery Investigations Computer forensic examination 1.2 \$ 495 \$ 594.00

Lomas, Adam 9/12/2024 Asset Recovery Investigations Preliminary review of documents 0.2 \$ 518 \$ 103.50

account.

Investigation Investigations Respond to inquiry from NPM Law[K. Mitchell] re: underlying bank documents 0.2 \$ 518 \$ 103.50 and Litigation respect to transfers cited in complaint. Lomas, Adam 9/12/2024 Asset Recovery Investigations Compose email to Paul Hastings and 0.3 \$ 518 \$ 155.25 Investigation NPM Law counsel teams re: investigative and Litigation updates [in lieu of standing weekly update meeting]. Lomas, Adam 9/12/2024 Asset Recovery Investigations Respond to inquiries from Paul Hastings 1.8 \$ 518 \$ 931.50 Investigation [L. Song and E. Sutton] re: sources of and Litigation information with respect to transfers cited

transaction and document review. Parizek, Pam 9/12/2024 Asset Recovery Investigations Review A. Lomas update re: revised Rule 0.6 \$ 712 \$ 427.20

[.1]. Review Paul Hastings request re:

data [.1].

Levenson, Patrick 9/12/2024 Asset Recovery Investigations Conducted

Ling, Bryant 9/12/2024 Asset Recovery Investigations - evidence handling and 0.8 \$ 495 \$ 396.00

Lomas, Adam 9/13/2024 Asset Recovery Investigations Review of bank transactions and other 0.8 \$ 518 \$ 414.00

and Litigation purchased for or otherwise titled in the

Investigation Investigations Respond to inquiry from Paul Hastings [E. Sutton] re: additional wire record 0.8 \$ 518 \$ 414.00

Parizek, Pam 9/13/2024 Asset Recovery Investigations Review J. Barker report re: 0.1 \$ 712 \$ 71.20 Investigation [.1].

Lomas, Adam 9/13/2024 Asset Recovery Investigations Respond to inquiry from NPM Law [P. 0.3 \$ 518 \$ 155.25 Investigation Linsey] re:

and Litigation transaction review. Barker, James 9/13/2024 Asset Recovery Investigations Correspondence/email - with S.Maza re 2.3 \$ 639 \$ 1,469.70

and Litigation findings. Ling, Bryant 9/13/2024 Asset Recovery Investigations lab delivery coordination 0.2 \$ 495 \$ 99.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 9/16/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law and A. Lomas re: supporting documents for 0.2 \$ 518 \$

Levenson, Patrick 9/16/2024 Asset Recovery

and Litigation Investigations tracing research. 2.0 \$ 378 \$

Lazarus, Jordan 9/16/2024 Asset Recovery

and Litigation Investigations Compile supporting documentation for avoidance action against 0.9 \$ 518 \$

and Litigation Investigations Compose email to internal Kroll team re:

purchases and/or financing. 0.4 \$ 518 \$

Levenson, Patrick 9/17/2024 Asset Recovery

and Litigation Investigations Internal meetings and discussions for

and Litigation Investigations Conduct Investigation -

A.Lomas, follow up research 1.8 \$ 639 \$

and Litigation Investigations Working meeting with J. Barker and P.

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.4 \$ 518 \$

Levenson, Patrick 9/17/2024 Asset Recovery

and Litigation Investigations tracing research. 0.5 \$ 378 \$

and Litigation Investigations Respond to inquiry from NPM Law [K.

and Litigation Investigations Review of documents produced by

and Litigation Investigations Incorporate

master transaction file. 0.5 \$ 518 \$

and Litigation Investigations Review and analysis of

bank account transactions; related updates to master transaction file. 4.2 \$ 518 \$

and Litigation Investigations Relativity document review of the

and Litigation Investigations Review and analysis of

updates to master transaction file. 0.3 \$ 518 \$

and Litigation Investigations Correspondence/email - with E.Sutton

Timekeeper Date Matter Task Narrative Hours Rate Amount

Levenson, Patrick 9/18/2024 Asset Recovery

and Litigation Investigations tracing research. 2.0 \$ 378 \$ 756.00

and Litigation Investigations Respond to inquiry from NPM Law [K.

related document and transaction review. 0.5 \$ 518 \$ 258.75

and Litigation Investigations Telephone call with NPM Law [P. Linsey] re:

and Litigation Investigations Provide meeting agenda [.1], attend weekly meeting with A. Lomas, J. Lazarus, J. Barker, Paul Hastings [L.

re:

Lazarus, Jordan 9/19/2024 Asset Recovery

and Litigation Investigations Compile transaction detail and related

Lazarus, Jordan 9/19/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, P. Parizek, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], and P.

business intelligence updates and related

and Litigation Investigations Review A. Lomas summary and related analyses re: transactions [.5]. 0.5 \$ 712 \$ 356.00

and Litigation Investigations Compose email to NPM Law [P. Linsey and K. Mitchell] re: banks for additional or amended Rule 2004 subpoena. 0.4 \$ 518 \$ 207.00

and Litigation Investigations Weekly call with Paul Hastings and NPM

Lazarus, Jordan 9/19/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law re: transactional detail for 0.2 \$ 518 \$ 103.50

and Litigation Investigations Prepare summary sources and uses of

Levenson, Patrick 9/19/2024 Asset Recovery

and Litigation Investigations tracing research. 3.0 \$ 378 \$

and Litigation Investigations Meeting re:

Hastings [L. Despins, N. Bassett, D. Barron, and L. Song]; NPM Law [P.

Timekeeper Date Matter Task Narrative Hours Rate Amount

Investigation Investigations Research with respect to transfers

Levenson, Patrick 9/20/2024 Asset Recovery

and Litigation Investigations tracing research. 1.0 \$ 378 \$

and Litigation Investigations Prepare schedule of

from Paul Hastings [L. Song]. 2.6 \$ 518 \$

Lazarus, Jordan 9/20/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law and A.

classification analysis. 0.2 \$ 518 \$

and Litigation Investigations Review and analysis of

master transaction file. 1.4 \$ 518 \$

Levenson, Patrick 9/23/2024 Asset Recovery

and Litigation Investigations Conducted public records and open

and Litigation Investigations Build out of template for due diligence analysis for entities to be considered in Second Omnibus Alter Ego complaint;

and Litigation Investigations Prepare schedule of

related email to Paul Hastings. 2.1 \$ 518 \$

Applications Review and revise matters, tasks and

and Litigation Investigations Review of documents produced by

Levenson, Patrick 9/24/2024 Asset Recovery

and Litigation Investigations Conducted public records and open

and Litigation Investigations Respond to inquiries from NPM Law [K. Mitchell] re: banks for additional and/or amended Rule 2004 subpoenas. 0.6 \$ 518 \$

Lazarus, Jordan 9/24/2024 General Debtor

Applications Billing - Prepare August 2024 Monthly

Kroll team re: related matters. 1.4 \$ 518 \$

Levenson, Patrick 9/24/2024 Asset Recovery

and Litigation Investigations Internal team meeting. 0.5 \$ 378 \$

Lazarus, Jordan 9/24/2024 Asset Recovery

and Litigation Investigations Review of August 2024 avoidance

and Litigation Investigations Review of updates on research re: certain prepared by P.

and Litigation Investigations Review of document productions from

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Respond to inquiries from Paul Hastings

Applications Review revisions to draft Monthly Fee

Lazarus, Jordan 9/24/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law re:

analysis and related matters. 0.2 \$ 518 \$

and Litigation Investigations Review of documents produced by 0.2 \$ 518 \$

and Litigation Investigations Review A. Lomas update re: new bank records. Alter ego due dilignce analysis,

to L. Despins for weekly agenda [.2]. 0.2 \$ 712 \$

and Litigation Investigations Research with respect to LLC bank accounts; compose related email to NPM Law [K.

and Litigation Investigations Avoidance Action Analysis: Meeting with NPM Law [P. Linsey and K.

requests for underlying analysis. 0.5 \$ 518 \$

Applications Review draft redacted Monthly fee

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.8 \$ 221 \$

Lazarus, Jordan 9/25/2024 Asset Recovery

and Litigation Investigations Analysis of transactions and related payments. 1.1 \$ 518 \$

Lazarus, Jordan 9/25/2024 General Debtor

Applications Billing - Prepare August 2024 Monthly

Kroll team re: related matters. 1.1 \$ 518 \$

and Litigation Investigations Prepare alter ego due diligence analysis

Lazarus, Jordan 9/25/2024 Asset Recovery

and Litigation Investigations Phone calls and correspondence with

charges and related payments. 1.1 \$ 518 \$

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.2 \$ 518 \$

and Litigation Investigations Research with respect to

with NPM Law [P. Linsey and K. Mitchell] and Paul Hastings [L. Song]. 1.7 \$ 518 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Incorporate

transactions into master transaction file. 0.6 \$ 518 \$

Lazarus, Jordan 9/26/2024 Asset Recovery

and Litigation Investigations Analysis of transactions and related payments. 2.8 \$ 518 \$

Lazarus, Jordan 9/26/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law [P. Linsey, K. Mitchell] and A. Lomas re:

and Litigation Investigations Review and analysis of

and Litigation Investigations Case Administration: Meeting with J. Welby and T. Spier re: transaction review

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.3 \$ 518 \$

and Litigation Investigations Compose email to NPM Law [K.

and Litigation Investigations Review and analysis of

bank transactions; related updates to master transaction file. 0.8 \$ 518 \$

and Litigation Investigations Review of documents provided by

master transaction file. 3.5 \$ 221 \$

Lazarus, Jordan 9/26/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], and NPM Law [P. Linsey and K.

and Litigation Investigations Meeting re: bank records for

investigative updates; with Paul Hastings [L. Despins, N. Basset, D. Barron, and L. Song], NPM Law [P. Linsey and K. Mitchell], and J. Lazarus. 0.6 \$ 518 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Prepare alter ego due diligence analysis

and Litigation Investigations Review and analysis of

updates to master transaction file. 5.0 \$ 221 \$

and Litigation Investigations Compose email to J. Barker and P.

related transaction and document review. 0.7 \$ 518 \$

and Litigation Investigations Incorporate

into master transaction file. 0.7 \$ 518 \$

and Litigation Investigations Research with respect to

Levenson, Patrick 9/27/2024 Asset Recovery

and Litigation Investigations Conducted public records and open